The Winter Package is an ambitious proposal for an energy policy framework meant to deliver on the commitment of the European Union to make ‘Efficiency First’ a guiding policy principle in energy policymaking. However, beyond the high-level commitment, many areas of the Winter Package fall short of comprehensively adopting the Efficiency First principle.

In this assessment by the Regulatory Assistance Project (RAP) and the Buildings Performance Institute Europe (BPIE), we assign a rating of “Supports Efficiency First” (green), “Needs Improvement” (yellow), and “Inconsistent with Efficiency First” (red) to key elements of the Winter Package, including components of the revised Energy Efficiency Directive (EED), the Energy Performance of Buildings Directive (EPBD), the Directive on common rules for the Internal Energy Market for electricity (IEM), the Regulation on the electricity market, and the Regulation on Governance of the Energy Union.

It is important to get each part of the Winter Package right—we need a well-designed EED as a driver for energy efficiency improvements across the economy, an ambitious Energy Performance of Buildings Directive to avoid lock-in into inefficient new building infrastructure, an Internal Energy Market that puts demand-side resources on an equal footing with the supply side, and a robust monitoring, reporting, and course-correction regime under the Governance Regulation.